On September 27, 2026, Germany is set to roll out new regulations that will significantly alter the landscape of sustainability labels and certification schemes. The changes come as part of the Third Act Amending the Act Against Unfair Competition (UWG), which implements the EU EmpCo Directive (2024/825). These updated regulations will require companies using environmental, social, or employer-related seals to adhere to stricter EU standards, ensuring that their claims are backed by credible and transparent certification systems.
The new framework will impose tighter controls on labels that lack recognition from established certification systems or official public authorities. This affects not just environmental claims but could extend to social criteria, including workplace conditions, employee satisfaction, fairness, and diversity, depending on the seal in use. Under the updated rules, valid certification schemes must adhere to several requirements, such as transparent documentation, publicly available criteria, equal access for organizations, and independent third-party verification.
International companies, including those outside Germany, might be impacted if they use sustainability or employer seals targeting German consumers, employees, or job applicants. Businesses are advised to assess their certification providers and ensure robust documentation and verification processes are in place before these regulations take effect. This shift emphasizes the importance of a credible and independently verified certification system over merely evaluating whether a claim is misleading.
Organizations with transparent and reliable certification processes stand to gain increased trust, while those relying on unsupported marketing labels could face legal challenges. Industry experts suggest that businesses prepare by thoroughly checking certification criteria, maintaining evidence of evaluation procedures, and ensuring all supporting documents are readily accessible. Additionally, seeking legal advice on specific compliance issues related to competition law is recommended.
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